Justia Hawaii Supreme Court Opinion Summaries

The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) and the decision of the circuit court affirming the decision of the Board of Trustees of the Employees' Retirement System of Hawai'i (ERS Board) denying Plaintiff's application for service-connected disability retirement benefits, holding that the ERS Board clearly erred in finding that Plaintiff's permanent capacity resulted from an "occupational hazard."Specifically, the ERS Board found that Plaintiff's permanent incapacity did not result from "a danger or risk which is inherent in, and concomitant to," her "particular occupation or particular job," which was "not a risk common to employment in general." The circuit court and ICA affirmed. The Supreme Court vacated the lower courts' decisions and remanded the case to the ERS Board for further proceedings, holding that the ERS Board added a requirement to the definition of "occupational hazard" that does not exist in the law. View "Quel v. Board of Trustees, Employees’ Retirement System of Hawai'i" on Justia Law

On Defendant's appeal from his convictions of driving without a license and of no motor vehicle insurance, the Supreme Court vacated the judgment of the district court and the intermediate court of appeals (ICA) and remanded this case to the district court for further proceedings, holding that there was no knowing and intelligent waiver of Defendant's fundamental right to a jury trial.Specifically, the Court held (1) the State proved beyond a reasonable doubt that Defendant was not in constructive possession of a license from Mexico or Canada, which would have exempted him from licensing requirements pursuant to Haw. Rev. Stat. 286-105; (2) the ICA erred by requiring Defendant to present evidence of a "borrower/lender relationship" with the registered owner of the vehicle to assert the "good faith lack of knowledge" defense, but this error did not require vacating Defendant's no motor vehicle insurance conviction; but (3) there was no valid waiver of Defendant's right to a jury trial on the charge of driving without a license, and therefore, Defendant's convictions must be vacated and the matter remanded for further proceedings. View "State v. Domut" on Justia Law

In this compensation dispute based on an oral agreement between Plaintiff and Defendants the Supreme Court affirmed the intermediate court of appeals' (ICA) judgment on appeal affirming the circuit court's final judgment, holding that the circuit court did not abuse its discretion in denying Defendants' Haw. R. Civ. P. 55(c) motion to set aside entry of default and did not err in its other rulings.The circuit court entered default and subsequent default judgment as to certain claims against defendants. After a bench trial regarding damages on the remaining claims the circuit court entered judgment in favor of Plaintiff and against Defendants. The ICA affirmed. The Supreme Court affirmed, holding (1) the circuit court did not abuse its discretion in denying Defendants' motion to set aside entry of default; and (2) prospectively, a Rule 55(c) motion to set aside entry of default is to be evaluated based only on whether there has been a showing of "good cause." View "Chen v. Mah" on Justia Law

The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) and the circuit court's judgment of conviction and sentence, holding that the circuit court abused its discretion in denying Defendant's challenge for cause of Juror 48, an error that required that Defendant's conviction be vacated, but that double jeopardy did not preclude a retrial.Defendant was convicted of two counts of theft and one count of criminal property damage. On appeal, Defendant argued, among other things, that the circuit court erred by denying his challenge to two prospective jurors for cause, thereby violating his right to peremptory challenges. The ICA affirmed. The Supreme Court held that Defendant's conviction must be vacated and the case remanded for a new trial because the circuit court improperly denied Defendant's challenge for cause of Juror 48, which required him to exercise one of his peremptory challenges to excuse that juror and caused him to exhaust his peremptory challenge, which impaired his right to exercise a peremptory challenge on a different juror. But because there was substantial evidence to support Defendant's convictions, double jeopardy principles did not preclude a retrial. View "State v. Carroll" on Justia Law

In this foreclosure dispute, the Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) affirming the circuit court's determination of lien priority between the Villages of Kapolei Association's (Association) lien and the Hawai'i Housing Finance and Development Corporation's (HHFDC) competing lien and the valuation of HHFDC's senior lien, holding that the ICA did not err.Specifically, the Court held (1) the ICA did not err by affirming the circuit court's alleged retroactive application of Haw. Rev. Stat. 201H-47 to rule that the HHFDC's lien was senior and superior to the Association's liens; (2) the ICA did not err in determining the appraisal process applied; and (3) the ICA did not err by holding that HHFDC had standing to enforce a shared appreciation or equity agreement between another party and HHFDC's predecessor in interest. View "American Savings Bank, F.S.B. v. Chan" on Justia Law

In this taxation dispute between the County of Maui and Appellees, which leased land on the island of Maui to operate their wind farms, the Supreme Court upheld the Tax Appeals Court's (TAC) final judgment in favor of Appellees, holding that the TAC properly held that the County exceeded its constitutional authority by amending Maui County Code 3.48.005 to expand its definition of "real property" to include "personal property."The County included the value of Appellees' wind turbine in their real property tax assessments and redefined the term "real property" within section 3.48.005 of the MCC to include wind turbines for that purpose. The TAC concluded that the County exceeded its authority under Haw. Const. art. VIII, 3 because the delegates to the 1978 Constitutional Convention did not intend to grant counties the power to redefine "real property." The Supreme Court affirmed, holding that the County exceeded its constitutional power when it amended MCC 6.48.005 to redefine "real property." View "In re Tax Appeal of Kaheawa Wind Power, LLC v. County of Maui" on Justia Law

In this foreclosure case, the Supreme Court held that the circuit court's award of a forfeited down payment as damages to the Association of the Owners of the Kumulani of the Uplands at Mauna Kea, creditors in the judicial foreclosure action, was an abuse of discretion.In response to a pair of post-judgment motions, the circuit court entered two orders. The first order found OneWest Bank, F.S.B., the foreclosing mortgagee and winning bidder at the foreclosure auction, liable for damages in an amount equal to its down payment for failure to close the foreclosure sale. The second order awarded the down payment as expectation damages to the association, a junior lienholder. On appeal, OneWest challenged the circuit court's jurisdiction to assess damages against OneWest and award them to the association. The Supreme Court held that because, pursuant to Haw. Rev. Stat. 667-3, creditors in a judicial foreclosure action are entitled to payment according to the priority of their liens, the circuit court erred by awarding damages to the Association rather than by applying the down payment amount to reduce the debt owed to OneWest. View "OneWest Bank, F.S.B. v. Ass'n of the Owners of the Kumulani at the Uplands at Mauna Kea" on Justia Law

The Supreme Court vacated Defendant's conviction on the charge of assault in the third degree, holding that the deputy prosecuting attorney's elicitation of evidence regarding Child Welfare Services' involvement in violation of a defense motion in limine was improper and not harmless beyond a reasonable doubt.Defendant was charged with assault in the second degree against his minor son. A jury found Defendant guilty of the lesser included offense of assault in the third degree. On appeal, Defendant argued that the family court plainly erred by failing to strike certain improper opening statements made by the deputy prosecuting attorney and by admitting certain x-rays into evidence without the necessary foundation. The intermediate court of appeals affirmed. The Supreme Court set aside the conviction, holding (1) the prosecutor improperly elicited evidence, and the error affected Defendant's substantial rights and was not harmless beyond a reasonable doubt; (2) there was insufficient foundation for admission of the contested x-rays into evidence; and (3) the conviction of assault in the third degree was supported by substantial evidence. View "State v. Williams" on Justia Law

The Supreme Court vacated Defendant's conviction of kidnapping, holding that the circuit court erred in failing to instruct the jury that the "restraint" required to support a kidnapping conviction under Haw. Rev. Stat. 707-720(1)(d) is restraint in excess of any restraint incidental to the infliction or intended infliction of bodily injury or subjection or intended subjection of a person to a sexual offense.Defendant was charged with one count of kidnapping and one count of third degree assault in connection with a single incident. The third degree assault count was dismissed before trial, and, after a trial, Defendant was found guilty on the kidnapping count. The Supreme Court reversed the conviction, holding that the circuit court plainly erred in not instructing the jury that Defendant's restraint of the complaining witness had to be restraint in excess of restraint incidental to any intended infliction of bodily injury or a sexual offense upon the complaining witness. View "State v. Sheffield" on Justia Law

The Supreme Court affirmed in part and vacated in part the judgment of the intermediate court of appeals (ICA) in this litigation concerning a dispute arising from a 1999 contract regarding the sale of approximately twenty-three acres of land in Honualua Maui, holding the the ICA erred by holding that Wailea Resort Company was clearly entitled to certain funds but otherwise did not err.The parties in this consolidated appeal were Michael Szymanski, Wailea, and ADOA-Shinwa Development and Shinwa Golf Hawai'i Company (collectively, Shinwa). Szymanski filed this application seeking a writ of certiorari raising seven questions. The Supreme Court held (1) the questions relating to the disqualification of the Honorable Rhonda I.L. Loo were without merit; (2) the ICA did not err in its application of the law of the case doctrine to the issue of whether the ICA gravely erred when it declined to review whether the Honorable Peter T. Cahill's 2015 order entering final judgment improperly dismissed with prejudice Szymanski's third-party complaint against Shinwa; and (3) the ICA erred by holding that Wailea was clearly entitled to certain funds and by affirming the circuit court's disbursal of funds. View "Title Guaranty Escrow Services, Inc. v. Wailea Resort Co., Ltd." on Justia Law